IR 05000010/1976015
| ML19340A857 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/29/1976 |
| From: | Kohler J, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A848 | List: |
| References | |
| 50-010-76-15, 50-10-76-15, 50-237-76-18, 50-249-76-16, NUDOCS 8009040674 | |
| Download: ML19340A857 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report of Operations Inspection i
IE aspection Report No. 050-010/76-15 IE Inspection Report No. 050-237/76-18
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IE Inspection Report No. 050-249/76-16
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Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 Dresden Nuclear Power Station Licenses No. DPR-2 Units 1, 2 and 3 No. DPR-19
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Morris, Illinois.
and No. DPR-25 Category:
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Type of Licensee:
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Type of Inspection:
Routine, Announced
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Dates of Inspection: July 7-8 and 13-16,-1976 7 f. /6U.v
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J. E. Kohler 7,/> ff' / p Principal Inspector:
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i Accompanying Inspectors: None i
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Other' Accompanying Personnel: Nonc
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l Reviewed By:
. S.
le, Chief
Nuclear Support Section 7 (Dafe)
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SUMMARY OF FINDINGS s
i Inspection Summary
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The inspection on July 7-8, and 13-16, (Unit 1, 4~15), (Unit 2, 76-18)
and (Unit 3, 76-16): Consisted of a review of t -
licensee's onsite review organizations and an inspection of variou. work request packages documenting the results of safety related maintenance activities.
Two items of noncompliance were identified dealing with failure to maintain records and failure to adhere to procedures-in the QA Manual.
Enforcement Items Infraction (Units 2 and 3)
Contrary to Technical Specification 6.2.A.6, the licensee's approved QA Manual procedure QP8-51 and QP10-51 was not followed for maintenance performed on safety related equipment, in that "O" rings having a safety related part number and listed as material used in the rebuild of the spare recirculation pump seals did not have the two-part red tag in the completed work request package.
(Paragraph 4, Report Details)
Deficiency (Units 2 and 3)
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Contrary to Technical Specification 6.5.A.2, test records did'not
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describe the action taken when a seal flow test failed to meet the acceptance criteria specified in procedure 36-249 which deals with repair and rebuilding of the recirculation pump seals.
(Paragraph 3, Report Details)
Licensee Action on Previously Identified Enforcement Items None.
Other Significant Items A.
Systems and Components None.
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B.
Facility Items (Plans and Procedures)
The licensee committed to describe in the response to this inspection report the mechanism whereby safety related parts are reclassified to nonsafety related, and the applicable criteria-2-
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'used to support the reclassification.
In addition, the response
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will include a description of the documentation at the site necessary to support these reclassifications as well as the
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method used by the Quality Control Department to ensure that proper documentation exists in the completed work request package.
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Managerial Items
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D.
Noncompliance Identified and Corrected by Licensee None.
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Deviations None.
F.
Status of Previously-Reported Unresolved Items
None.
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Management Interview
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A managament interview was conducted by Mr. Kohler with Mr. Stephenson,
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Station Superintendent, and other members of his staff at the conclusion
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of the inspection. The following items were discussed.
i A.
The inspector stated that he considered the licensee's failure to document that the recirculation pump seal maintenance procedure had been followed was an item of noncompliance. The licensee
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acknowledged this.
(Paragraph 3, Report Details)
B.
The inspector stated that he considered the' licensee's failure to follow the QA' Manual which specifies documentation required for safety related maintenance activities to be an item of noncompliance. The licensee acknowledged this.
(Paragraph 4, i
Report Details)
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s C.
The inspector questioned the licensee pertaining to the mechanism used to reclassify parts from safety related to nonsafety related.
The licensee committed to describe his mechanism in the response i
to this inspection report.
(Paragraph'5, Report Details)
D.
The inspector stated that he had reviewed the licensee's onsite review-~ organization and found no' items of noncompliance.
(Paragraph 7. Report Details)
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'MPORT DETAILS i
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1.
Persons Contacted B. Stephenson, Station Superintendent J. Abel, Administrative Assistant F. Willoford, Quality Assurance E. Eenigenburg, Maintenance Engineer T. Watts, Technical Staff Supervisor M. Hummel, Station Storekeeper J. Scholtes, Maintenance Department 2.
Safety Related Maintenance The inspector reviewed documentation related to safety related maintenance activities performed at the Dresden Station in the last six months to determine whether applicable administrative procedures and Technical Specifications were followed. The maintenance activities reviewed, broken down by systems, are listed below, a.
Reactor Coolant System Unit 1 Repair of Reactor Recirculation Pump i
Unit 1 Repair of Main Steam Line Isolation Valve (WR12230)
Units 2/3 Rebuild Spare Recirculation Pump Seal (WR3846)
Unit 2 Inspect and Repair Recirculation Pump Seal (WR3847)
Units 2/3 Rebuild Spare Recirculation Pump Seal (WR3846)
Units 2/3 Rebuild Spare Recirculation Pump Seal (WR2757)
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Reactivity and Power Control Unit 1 Check and Replace Incore Strings (WR1557)
Unit 1 Removal and Installation of Control Rod Drive (WR11950)
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Unit 2 Installation and Removal of Control Red Drive (WR1627)
Unit 3 Investigation of Inoperable Trip on Rod Block Monitor-4-
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Power Conversion and Auxiliary Systems i
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Unit 1 Safety System MG Set A Brush Inspection (WR3400)
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Unit ~1 Jafety System MG Set'B' Brush Inspection (WR3399)
Unit'2 Remove, Inspect, and Test 6 Inch Safety (WR11976)
Unit 2 Overhaul and Test Safety (WR3395)
Unit 3 Remove, Inspect and Test Safety Valve (WR4410)
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Unit 3 Main Steam Line Isolation Valve Test (WR2482)
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Containment System Unit 1
. Sphere Isolation Vent Inlet Valve Test (WR4009)
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Unit 1 Sphere Personnel. Air Lock Repair (WR12318)
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Unit.2 Torus Snubber Test (WR4258)
Unit 2 Leak Test of Personnel Air Lock e.
Emergency Core Cooling Unit 1 Calibrate Set Point on Unit 1 Flow Gauges (WR606)
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Unit 1 Core Spray Valve (WR607)
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Unit 2 Replace LPCI Pump-Seal (WR4515)
Unit 2 ECCS Jockey Pump Check Valve Inspection and i
Repair (WR3298)
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Engineered Safety Features Unit 1 Steam Drum Safety Valve Removal and Inspection (WR10843)
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Unit 1 Steam Drum Safety Valve Grind Out (WR28)
Unit 2 Inspect and Fill Drywell Snubbers (WR3709)
Unit 3 Investigate Downscales on Unit 3 Yarway (WR5077)
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Electrical i
i Annual-Inspection of Number 2/3 Diesel Generator (WR1360)
Annual Diesel Generator Inspection (WR4781)
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Unit-1 Motor Distribution Panel (WR1320)
Unit-1 Safety System MG Set (WR3399)
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3.
Recirculation Pump Seal Flow Test
'.ocedure 36-249 dealing with recirculation pump seal work was reviewed in connection with several work request packages initiated to rebuild the recirculation pump seals. The procedure specifies the performance of a seal flow test prior to rebuilding of the seal in order to determine whether acid cleaning of the orifice is necessary.
Acceptance criteria for the flow cest is specified in the procemire and calls for contacting the seal vendor representive if the flow test exceeds the acceptance criteria by more than i 10% of the specified values.
In two instances, WR3846 and WR3847, the seal flow acceptance criteria was exceeded, however, the procedure indicated that the vendor representative was not contacted.
During the exit interview the inspector stated that the licensee had failed to follow the seal flow test procedure and that this was considered an item of noncompliance with Technical
Specificati.n 6.2.A.
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The licensee stated that the vendor representative actually was contacted but the procedure was improperly filled out.
He corrected the work request package to indicate that the vendor representative had been contacted and instructed maintenance personnel to follow the recirculation seal flow test procedure in the future. The inspector considers the licensee's corrective action appropriate and no. response to this item of noncompliance is necessary.
In light of this information the item of noncompliance is considered a deficiency for failure to maintain records as required by Technical Specification 6.5.A.2.
4.
Quality Control
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The Commonwealth Edison Quality Assurance Manual states that parts that are classified as safety related have an alpha character after the third digit of the material stock number.
In addition, the QA Manual (QP8-51, QP10-51) states the two-part red tag that identifies each safety related part should be included as final documentation in the completed work request package.
In two instances, WR3846 and WR2984, "0" rings classified as safety related,
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and having part numbers 232All and 232A14 respectively were used (, 3 in the rebuilding of the recirculation pump seals, but no red tags (which indicate the purchase order number) were included in the
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final work request package.
During the exit, the inspector suggested that the purchase orJer number for parts classified as safety related (having an alpha identified after the third digit of the material part number)
be included on the material request form issued by the storekeeper, in addition to the two-part red tag.
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The inspector stated that the incomplete documentation for work performed on safety related equipment represented an item of noncompliance wich Technical Specification 6.2.A.6.
In addition the incomplete work request documentation was not detected by the station Quality Control Department that signed of f cn the completed work request package.
5.
Declassification of Safety Related Parts The licensee is declassifying safety related parts such as Byron Jackson "0" rings, part number 232All, to a nonsafety related classification. This became evident in review of the work requests performed on the spare recirculation pump seals.
Four work requests relating to these seals were reviewed.
Two work requests had the Commonwealth Edison two-part red tag in the completed work request
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packages while the remaining two did not.
However, all four work requests classified the "0" rings with a safety related part number.
The inspector asked the station storekeeper for the reason why the red tags were missing from WR3846 and WR2984. He stated that the part number was changed from safety to nonsafety and therefore the red tag was not necessary.
The inspector asked the licensee to describe the mechanism whereby parts were reclassified and the documentation at the site to support the reclassification, however, the licensee could not describe the reclassification mechanism.
The inspector stated that he interpretated the QA Manual to require red tags for all parts with numbers containing an alpha after the third digit (QP8-51) and that the Quality Control Department should inspect a work request package against this requirement.
The licensee agreed with the inspector's interpertation.
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(~T At the inspector's request, the licensee will include a section in the response to this inspection report which describes the mechanism that is used to reclassify parts from safety to nonsafety
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as well as the applicable criteria used for the reclassification.
In addition the response will include a description of the documentation at the site necessary to support these changes as well as the mechanism used by the Quality Control Department to ensure that the praper documentation exists in the work request package before the package is signed off by the Quality Control Department.
6.
Quarterly Review of Reportable Occurrences Several maintenance activities were selected for review in order to determine whether the events leading up to the request for maintenence constituted a reportable occurrence.
The following items were reviewed by the inspector and no discrepancies in the classification or reportability of the maintenance activities were found.
Plant Dgscription Reportability Dresden 1 Replace copper gasket Not Reported
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with flexatalic gasket Not Reportable on recirculation pump
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Dresden 1 Incore string checked Not Reported and replaced as necessary Not Reportable Dresden 2 ECCS Yarway Pump Reported Check Valve Inspection Reportable Dresden 2 Throughwa?' crack in Reported HPCI safe end Reportable Dresden 3 Investigate downscales on Not Reported Yarway level indicator Not Reportable Dresden 3 Rebuild spare recirculation Not Reported
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pump seal Not Reportable
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Organization and Administration The licensee's onsite review organization was inspected against the approved Administrative Procedure describing the details and-8-
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commitments made to conduct such a review. The licensee's onsite (~'
review consists of the following areas:
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Onsite review and investigation.
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Procedure review.
Onsite review of plant operations.
Onsite review of reportable occurrences and violations of Technical Specifications.
Onsite review of station orders.
Onsite review of proposed plant modifications.
Onsite audit functions.
In addition the qualification of the participants that are selected for the various onsite review organizations were inspected against the requirements of ANSil8. il.
No items of noncompliance with procedures or Technical Specification were found.
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